Stanley v. Patterson
| Decision Date | 20 September 2022 |
| Docket Number | S21G0405 |
| Parties | STANLEY v. PATTERSON et al. |
| Court | Georgia Supreme Court |
We granted certiorari in this case to decide whether the Court of Appeals erred in affirming the trial court's grant of a directed verdict in favor of Appellees, a court administrator and two municipal court case managers, based on quasi-judicial immunity. Appellees failed to remove a bind-over order from a stack of case files bound for the state court solicitor's office, catalyzing a chain reaction that eventually led to the improper arrest and jailing of Appellant. We hold that Appellees were not protected by quasi-judicial immunity because their alleged negligence was not committed during the performance of a "function normally performed by a judge." Heiskell v. Roberts, 295 Ga. 795, 801 (3) (a) (764 S.E.2d 368) (2014) (citing Mireles v. Waco, 502 U.S 9, 12-13 (112 S.Ct. 286, 116 L.Ed.2d 9) (1991)).
We therefore reverse the judgment of the Court of Appeals.
We also clarify our opinion in Withers v. Schroeder, 304 Ga 394 (819 S.E.2d 49) (2018). In that case, we held that a court administrator was protected by quasi-judicial immunity when completing a judicial function specifically assigned to the court by statute. Although we noted that the court administrator was acting as an "extension of the court" "[t]o the extent" that he acted at the judge's discretion, the decision turned on our conclusion that, under the particular circumstances of that case, the court administrator was exercising a judicial function. This remains the touchstone for judicial immunity.
Finally because the question of whether Appellees' actions were protected by official immunity was raised in their motion for a directed verdict but not resolved by the trial court, we direct the Court of Appeals to remand the case to the trial court for further proceedings.[1]
1. The largely undisputed record shows that Appellant was arrested in December 2013 for driving under the influence and summoned to appear in Atlanta Municipal Court. Although Appellant pled guilty to lesser charges in that court in July 2014 and was sentenced, the matter was forwarded in error to the State Court of Fulton County. Appellant did not receive notice that his case had been sent to the state court for prosecution.
Appellant's DUI case had been forwarded to the state court due to an error by two of the appellees, case managers employed by the Atlanta Municipal Court. Appellant's file, consisting of the bind-over order and related materials, was originally placed in a stack of case files bound over to the state court and intended to be walked over to the state court solicitor's office. After Appellant pled guilty, the judge rescinded the bind-over order, but the case managers failed to physically remove Appellant's file from the stack. One of the case managers sent an email to the municipal court clerk's office in an effort to stop the file from being forwarded, asking the clerk's office to "[p]lease pull it, and I will be down to retrieve it." But she did not retrieve Appellant's file, and it was forwarded to the state court solicitor for prosecution.
Because he was unaware proceedings against him had commenced in state court, Appellant failed to appear for an arraignment hearing in the State Court of Fulton County. A bench warrant was issued for his arrest in March 2016. In May 2016, during a routine traffic stop, he was arrested and spent the night in the Fulton County Jail. Appellant was later released, and the state court granted the solicitor's request for an order of nolle prosequi with respect to the charges against him. Appellant then brought suit against the Atlanta Municipal Court employees who had allowed his case file to be forwarded in error to the state court, alleging negligence and false arrest,[2] and that case proceeded to trial.
At the conclusion of Appellant's presentation of evidence, the trial court granted Appellees' motion for directed verdict on the ground that they were protected by quasi-judicial immunity, basing its decision on our opinion in Withers. In an unpublished opinion, the Court of Appeals agreed, holding that "the trial court correctly concluded that Appellees were acting as [an] 'extension of the court' or 'arm of the judge' such that they are immune from suit based on quasi-judicial immunity." (Punctuation omitted.) Stanley v. Patterson, 357 Ga.App. XXVI (Case No. A20A0987) (Oct. 21, 2020) (unpublished). We granted Appellant's petition for certiorari.
2. Appellant contends that Appellees were not protected by quasi-judicial immunity in failing to remove the bind-over order from the stack of case files to be walked over to the state court solicitor's office. We agree.
Absolute judicial immunity has protected judicial actions from suit since medieval times. See Forrester v. White, 484 U.S. 219, 225 (108 S.Ct. 538, 98 L.Ed.2d 555) (1988).[3] Indeed, "[f]ew doctrines were more solidly established at common law than the immunity of judges from liability for damages for acts committed within their judicial jurisdiction." Pierson v. Ray, 386 U.S. 547, 553-554 (87 S.Ct. 1213, 18 L.Ed.2d 288) (1967). Georgia similarly has recognized judicial immunity from state law claims for many years. See Withers, 304 Ga. at 396-397 (2). See also Heiskell, 295 Ga. at 801 (3) (a) (); Calhoun v. Little, 106 Ga. 336 (32 SE 86) (1898); Maddox v. Prescott, 214 Ga.App. 810 (449 S.E.2d 163) (1994); and Upshaw v. Oliver, 1 Dud. 241 (Ga. Super. Ct. 1832).
Because the historical rationale for judicial immunity was protecting judges in the impartial exercise of their independent judgment, the scope of judicial immunity has usually been limited to acts requiring the exercise of such judgment. See Antoine v. Byers &Anderson, Inc., 508 U.S. 429, 435-436 (II) (113 S.Ct. 2167, 124 L.Ed.2d 391) (1993). This Court has further specified that, in determining whether judicial immunity applies, the relevant inquiry is whether the actor was performing "a function normally performed by a judge." Heiskell, 295 Ga. at 801 (3) (a) (citing Mireles, 502 U.S. at 12-13). Accord Withers, 304 Ga. at 397-398 (2) (). Thus, ministerial or routine acts that do not require the exercise of judgment typically have not been afforded judicial immunity. See, e.g., Heiskell, 295 Ga. at 801 (3) (a) ().
In general, judicial functions are those "involved in resolving disputes between parties who have invoked the jurisdiction of a court.” Forrester, 484 U.S. at 227 (III). Accord Burns v. Reed, 500 U.S. 478, 500 (II) (111 S.Ct. 1934, 114 L.Ed.2d 547) (1991) (Scalia, J., concurring in part and dissenting in part) ( that judicial immunity attaches to "performance of the function of resolving disputes between parties, or of authoritatively adjudicating private rights"). Judicial functions are distinguished from "administrative, legislative, or executive functions that judges may on occasion be assigned by law to perform." Forrester, 484 U.S. at 227 (III). Although these other functions may be essential to the operation of the courts or the judicial system, nonjudicial functions have not traditionally been protected by judicial immunity. See Withers, 304 Ga. at 397 (2) ( that judges are not protected by judicial immunity for acts that are "nonjudicial" or taken in the complete absence of all judicial authority).
Because judicial immunity protects judicial actions, not merely judges, nonjudges may be protected by judicial immunity as well. Officials other than judges are sometimes authorized to make "discretionary judgment[s]" that are "'functionally comparable' to those [made by] judges." (Punctuation and citation omitted.) Antoine, 508 U.S. at 436 (II). When nonjudges perform these kinds of acts, we have concluded that they are protected by "quasi-judicial immunity."[4] Withers, 304 Ga. at 394. See also Housing Authority of City of Augusta v. Gould, 305 Ga. 545, 550 (826 S.E.2d 107) (2019) (). In this context, "quasi" refers to the identity of the actor, not to a different kind of immunity or action. In other words, quasi-judicial immunity applies when judicial immunity is extended to actions by nonjudges, so the same test, and limits, apply. See, e.g., Arthur Andersen &Co. v. Wilson, 256 Ga. 849, 850 (353 S.E.2d 466) (1987) (auditor appointed by trial court was "cloaked in judicial immunity"). Cf. Antoine, 508 U.S. at 435-436 (II) ().
Applying these principles here, Appellees' actions were not protected by quasi-judicial immunity. As discussed above, the lodestar of judicial and quasi-judicial immunity is whether the actions constitute "a function normally performed by a judge." Heiskell, 295 Ga. at 801 (3) (a) (citing Mireles, 502 U.S. at 12-13). The task at issue here - removing or failing to remove an order from a stack of case files - is a mere physical task requiring no "discretionary judgment" that is "'functionally comparable' to those [made by] judges." (Punctuation and citation omitted.) Antoine, 508 U.S. at 436 (II). The judicial action occurred much earlier in the chain of events, when the guilty plea was accepted and entered and the judge's responsibilities...
To continue reading
Request your trial